The European Court of Justice has just rendered a very positive decision that will impact the application of French Social contributions to non-French residents owning French real estate.
The Finance Act 2011 introduced a tough taxation regime for foreign trusts having French connections together with potentially wider ranging tax and reporting obligations imposed personally on trustees.
The French rules apply to all Trusts:
- Where any of the settlor, deemed settlor or beneficiary is a French tax resident.
- Or where the trustees hold certain French situs assets, even if the settlor, deemed settlor or beneficiary is not a French tax resident.
The first rectified Finance Act for 2011 introduced a new penalizing regime of taxation for foreign Trusts in
The French Tax Authorities (FTA) have now published their Decree (dated 15 September) providing a new deadline for
The first rectified Finance Act for 2011 dated 29th July 2011 (entry in force 31th July 2011) introduced a new penalizing regime of taxation for foreign Trusts in France, and new reporting obligations for the Trustees.
The Trustees have until 15 June 2013 to make their annual disclosure of the market value of the assets, rights or income capitalised in Trust. This reporting obligation applies to Trusts in existence on 1st January 2013.
Dans son dossier spécial Expatriation fiscale, l'Agefi Actifs présente les condéquences d'une expatriation vers la Suisse, la Belgique ou le
Royaume-Uni. Caroline Cohen y livre un entretien..